The CRA Is Calling: How Canadians Can Navigate CERB Repayments and Tax Audits in 2025 — With Legal Clarity
When the COVID-19 pandemic hit in 2020, it didn’t just disrupt lives — it reshaped our entire relationship to tax law. Programs like the Canada Emergency Response Benefit (CERB), the Canada Emergency Wage Subsidy (CEWS), and the Canada Emergency Business Account (CEBA) were launched in record time to keep people and businesses afloat. But now, five years later, the bill is coming due — and Ottawa is coming knocking. The Canada Revenue Agency (CRA), acting on behalf of the federal government, has shifted into one of the most aggressive audit cycles in recent memory.
If you’re an individual or business in Ontario — whether in Toronto, Ottawa, Oshawa, Windsor, Barrie, or anywhere in between — this shift matters. Whether you took CERB in 2020, hired temporary staff under wage subsidies, or simply filed taxes during uncertain times, you're now part of the CRA’s fast-expanding compliance agenda. For many, the question isn’t whether the agency will come knocking — but when.
This is the story of how we got here, where things are going in 2025, and how you can respond with confidence instead of anxiety.
The Pandemic’s Aftermath: A $97 Billion Question
In early 2020, CERB was rolled out in a matter of weeks — an emergency-use income program that paid $500 per week to Canadians who’d lost work. In total, more than $82 billion in CERB payments were issued, according to the Auditor General’s 2022 pandemic benefits report. What followed shocked lawmakers: at least $4.6 billion of that money was clearly overpaid — and a further $27 billion was paid to individuals or businesses who may not have qualified.
That includes individuals who continued working while collecting benefits, businesses whose revenue didn’t fall far enough to meet eligibility thresholds, and self-employed Canadians who may not have declared enough pre-pandemic income to qualify. There were also overpayments made due to system errors and a lack of real-time employer data when applications opened.
The CRA now believes that some portion of those payments should not have gone out — and it is determined to collect on that belief.
When the Auditor General revealed just how much had been issued without proper verification, the CRA publicly committed to a multi-year repayment and enforcement plan — and while many hoped it would focus on fraud only, the reality is that repayment demands are now targeting everyday Canadians and business owners across the country, including Ontario.
From Relief to Review: The CRA’s 2023–2025 Shift
At first, enforcement began quietly. Individuals started receiving letters in early 2023 asking for proof of CERB eligibility. Businesses received requests for payroll records and revenue comparisons linked to CEWS subsidies. By 2024, the CRA was openly telling the media that its focus had shifted from issuing benefits to recovering pandemic-era debt — and that repayment conversations “could last until 2030.”
A snapshot of recent headlines says it all:
CRA seeking CERB repayments from nearly 300,000 people — CTV News
Businesses given until Jan. 18 to repay CEBA loans — or face higher interest — Global News
CRA’s focus this year is pandemic benefits, crypto, and small business audits — Financial Post
Government to crack down on false CERB claims as part of new compliance initiative — CBC
The message is unmistakable: The CRA is no longer asking. It is enforcing. And the enforcement isn’t limited to major cities or big corporations — it’s landing directly in mailboxes from Ottawa to Oshawa to Oakville.
Why Individuals Across Ontario Are Being Contacted
Some Canadians who applied for CERB genuinely believed they were eligible. They earned just over the minimum $5,000 in income in 2019 or early 2020. They saw their hours or work evaporate overnight. They filed their taxes properly. And yet today they’re being told they owe $10,000, $14,000 or more in repayments — and that interest is accumulating.
This is happening even to people who acted in good faith. The reason is simple: the CRA now requires Canadians to prove they were eligible — not the other way around.
That means finding paperwork from five years ago that many never thought they'd need again. If you were self-employed, in contract work, or had fluctuating income — especially in areas like Ottawa’s public sector-adjacent gig economy — you're much more likely to now fall into a compliance-risk category.
What’s Happening to Businesses
Small and medium-sized businesses across Ontario — from tech firms in Waterloo to restaurants in Ottawa’s ByWard Market — often received multiple types of pandemic support: wage subsidies, rent assistance, forgivable CEBA loans, or direct benefits to owner-operators through CERB.
The CRA is now asking whether those businesses truly met the eligibility and reporting criteria, whether subsidies were applied properly to payroll, and whether those CEBA loans were used for valid business expenses.
The trouble is, once a business is selected for one of these reviews, it is rarely limited to a single program. Many businesses begin with a CEWS subsidy question and end up in payroll, HST, dividend, or income tax audits.
As one Toronto Star columnist put it in 2024: “A CERB letter might feel like a paperwork hassle, but for many small business owners, it’s turning into the entry point to a full-blown tax audit.”
And those audits aren’t happening just in the GTA — they’re growing across regional hubs.
Why More Canadians Are Working With Tax Lawyers, Not Just Accountants
Before the pandemic, accountants handled most CRA issues. But pandemic-related disputes are different: they now involve legal concepts — not just numbers. These cases are about eligibility, administrative fairness, alleged misrepresentation, and the legal framework behind government debt collections.
These are not just accounting matters — they are legal matters. Only a lawyer can negotiate disputes under solicitor-client privilege, file tax appeals in Federal Court or the Tax Court of Canada, or argue matters of fairness when the CRA oversteps.
That’s why more people and businesses across Ontario are turning to firms like Fiszman Law for advice and representation.
What to Do If You Receive a CRA Letter About CERB or Pandemic Benefits
The worst thing you can do? Ignore it. Even if you believe the CRA is wrong, silence is treated as agreement. The longer you wait, the more power the CRA has to escalate the issue — including via interest, penalties, wage garnishment, collections agents, or freezing future refunds.
The best thing you can do is respond strategically, and early. The CRA is not obligated to guide you, nor does it have any duty to explain how to defend yourself. And when those envelopes arrive marked “Government of Canada,” it’s not just about tax — it’s Ottawa enforcing its authority.
Representation matters — especially before things escalate.
Can You Still Fix It Before CRA Gets Involved?
Yes — but the path depends on the program. For CERB/CRB/CRSB/CWLB, you can repay voluntarily (no interest or penalties on benefit overpayments) and, if you disagree with a denial or overpayment, request a second review within 30 days; if still denied, apply for Federal Court judicial review within 30 days. For CEWS/CERS, file a Notice of Objection within 90 days of any reassessment; unresolved disputes go to the Tax Court of Canada. For CEBA, forgiveness questions run through your bank/EDC, while the CRA handles collections and payment arrangements on assigned loans. The Voluntary Disclosures Program is for correcting tax filings, not benefit or CEBA decisions.
The Legal Reality of 2025
Pandemic programs have shifted from relief to enforcement — but the law gives you clear routes: benefit reviews → Federal Court JR, tax/subsidy assessments → Objection → Tax Court, CEBA → lender/EDC + CRA collections. The sooner you engage, the more leverage you keep.
Your Tax Problem Is Solvable. You just need a strategy.
Fiszman Law works with taxpayers across Ontario — individuals, small businesses, incorporated professionals, tech founders, contractors, and entrepreneurs. We’re not here to judge how you got here. We’re here to get you out — strategically, respectfully, and with the goal of limiting financial and legal harm.
If the CRA is calling — or if you think they might — we can help.
